I have recently been engulfed with a number of matters that were or are still headed to court, so I found the comments in a recent paper on the decision in the Estate of Gallagher curious.1 After quoting normalizing adjustments enumerated in the taxpayer's expert's report that the Tax Court rejected because the judge did not understand the rationale for the adjustments, the authors state, “the present authors do not know why the Tax Court could not understand the financial statement adjustments…If the …report explanations were insufficient, then few adjustments to financial statements in business appraisal